Four years after the last update, a new version of the BRC Standard for Packaging and Packaging Materials will be released on July 1, 2015. Now the fifth version aims to reflect the changing expectations and requirements of diverse stakeholders and comes into force on January 1, 2016.

Structure & Fundamentals

As before, the standard distinguishes between two categories with different hygiene requirements. However, it should be noted that the names of the two categories as well as those of the underlying systematics have changed. Since the classification in the categories is based on the intended use of the materials and not on the risk potential, the term risk is no longer used in this context. The "High Hygiene" category (previously "High Hygiene Risk") applies to products that come into direct contact with food or other hygiene-sensitive products. All other packaging materials (secondary and tertiary packaging as well as labels) fall under the "Basic Hygiene" category (previously "Low Hygiene Risk").

The eight so-called Fundamentals remain unchanged except for a change in numbering.

Changes per chapter

Management commitment and continuous improvement

The few changes are limited to language rewording and changes in the order to make them easier to understand.

Hazard and risk management system

Here, too, the changes are limited. In section 2.2, the term "quality" has now been included in addition to product safety and integrity. This means not only that quality-related risks should also be considered in the risk and hazard analysis, but also that they can be managed as part of the preventive programs.

In addition, the risks of migration as well as malicious product tampering are also considered in this chapter.

Product safety and quality management system

The order of requirements has been changed to match the operational flow. There is also a new clause for supplier management that is specific to service providers and complements the existing clause 3.5 for raw material suppliers.

Standards for the operating site

A number of requirements have been added on the subject of pest control. Sites that perform pest control in-house must ensure that systematic effectiveness control is in place. In addition, the functionality of all pest control resources must be ensured and all employees must be able to recognize and report a pest infestation.

Furthermore, individual clauses in this chapter have also been moved or recombined. Clause 4.8 - Personnel Facilities will become part of Chapter 6 in the new version; Clause 5.8 - Foreign Object Contamination Control will fall under Chapter 4.

Product and process control

Two new clauses jump out at you here: a new clause 5.2 defines responsibility for "Graphic Design." Sites that do their own graphic design must be able to ensure the integrity of artwork.

The new Clause 5.8 for Receiving has evolved from Section 4.12 - Transportation, Storage and Distribution, which has been completely revised. Storage requirements are located in the new version under 5.9; shipping and transportation are covered under 5.10.

Personnel

As already written, the topic of personnel facilities is no longer covered in 4.8 but in Chapter 6. In turn, clause 6.2 Personnel access and movements moves to chapter 4.

Evaluation system

To provide a further incentive for continuous improvement, a level of excellence has been introduced. The new "AA" classification is intended for companies that have already achieved Grade A. Companies with a maximum of five minor nonconformities are classified in the new category. The number of maximum possible minors of the previous category A remains unchanged.

Unannounced audits & additional modules

The audit protocol provides for the possibility of conducting unannounced audits. The unannounced audits are optional. There is also the possibility to combine the BRC audit with optional additional modules such as the Environmental Awareness Module (EAM) and the Traded Goods Module (additional purchase of finished packaging).

Schedule

After the release on July 1, 2015, there will be a preparation period of six months. The application of the new version 5 is mandatory for all audits that take place after January 1, 2016. Before that, certification according to the new version is not possible.

Author
Dr. Thijs Willaert

Dr. Thijs Willaert is the Global Director of Sustainability Services. In this role, he is responsible for the entire ESG service portfolio of DQS. His areas of interest include sustainable procurement, human rights due diligence and ESG audits.

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